Ein europäisches »Full Faith and Credit« für Rechtsgeschäfte? - Über die (partielle) Ersetzung des IPR durch ein Anerkennungssystem

European »Full Faith and Credit« for Private Acts? On the (Partial) Replacement of PIL with a System of Recognition. In EU law, there are increasing signs of a fundamental change in methodology: Step by step, the EU legislature could be moving towards extending the rules on the recognition of judgments to private acts. Taken to its logical conclusion, the (quasi-)procedural recognition of private acts means that there is no need for an ex post review of the validity of these acts in the Member State of recognition. Therefore, in the Member State of recognition, the application of conflict-of-law or substantive law rules is no longer admissible. At first glance, the (quasi-)procedural recognition of private acts appears to be incompatible with the established principles of private international law. It is therefore likely to meet with considerable resistance. However, upon closer look, it could prove to be an effective tool in the creation of a single European judicial area.